Correspondence 0001213900-24-004695 from Li Bang International Corp Inc. (LBGJ) (CIK 0001896425) (LBGJ)
Li Bang International Corp Inc. (LBGJ) (CIK 0001896425)
Date: Jan. 19, 2024 · CIK: 0001896425 · Accession: 0001213900-24-004695
AI Filing Summary & Sentiment
File numbers found in text: 333-262367
Referenced dates: January 8, 2024
Letter
Via Edgar Correspondence Division of Corporation Finance Office of Technology Re: Li Bang International Corporation Inc. Amendment No. 7 to Registration Statement on Form F-1 Filed December 18, 2023 File No. 333-262367
Dear Mr. Kauten:
This letter is in response to the letter dated January 8, 2024 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) addressed to Li Bang International Corporation Inc. (the “Company”, “we”, and “our”). For ease of reference, we have recited SEC’s comments in this response and numbered them accordingly. An amended registration statement on Form F-1 (the “Amendment No. 8 to the Registration Statement”) is being submitted to accompany this letter.
Amendment No. 7 to Registration Statement on Form F-1
Consolidated Statements of Cash Flows, page F-6
1) Based on your disclosure on page 61, it appears that the purchase of fixed deposits in 2023 are reflected as an increase in prepaid expenses and other current assets within cash used in operating activities. Considering the fixed deposits are classified as a noncurrent asset, please explain why you present the amounts within operating activities and not as an investing activity. Please provide us with the authoritative guidance that supports your presentation.
RESPONSE: We note the Staff’s comment, and in response thereto, respectfully advise the Staff that we have modified the consolidated statements of cash flows and presented the fixed deposits in investing activities. Please refer to page F-6 in the Amendment No. 8 to the Registration Statement.
Notes to Consolidated Financial Statements
Note 18 - Subsequent Events, page F-27
2) You disclose that you have evaluated subsequent events and transactions that occurred after the balance sheet date through the date that the financial statements were available to be issued. Please revise to include such date. Refer to ASC 855-10-50-1.
RESPONSE: We note the Staff’s comment, and in response thereto, respectfully advise the Staff that we have revised the disclosure on page F-27 in the Amendment No. 8 to the Registration Statement.
We hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein, please contact our securities counsel William S. Rosenstadt, Esq., or Mengyi “Jason” Ye, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or jye@orllp.legal.
Li Bang International Corporation Inc.
/s/ Huang Feng
Name: Huang Feng
Title: Chief Executive Officer
Show Raw Text
CORRESP
1
filename1.htm
LI BANG INTERNATIONAL CORPORATION INC.
No. 190 Xizhang Road, Gushan Town
Jiangyin City, Jiangsu Province
People’s Republic of China
January 19, 2024
Via Edgar Correspondence
Jeff Kauten
Division of Corporation Finance
Office of Technology
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C., 20549
Re:
Li Bang International Corporation Inc.
Amendment No. 7 to Registration Statement
on Form F-1
Filed December 18, 2023
File No. 333-262367
Dear Mr. Kauten:
This letter is in response to the letter dated
January 8, 2024 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) addressed
to Li Bang International Corporation Inc. (the “Company”, “we”, and “our”). For ease of reference,
we have recited SEC’s comments in this response and numbered them accordingly. An amended registration statement on Form F-1 (the
“Amendment No. 8 to the Registration Statement”) is being submitted to accompany this letter.
Amendment No. 7 to Registration Statement
on Form F-1
Consolidated Statements of Cash Flows, page
F-6
1)
Based on your disclosure on page 61, it appears that the purchase of fixed deposits in 2023 are reflected as an increase in prepaid expenses and other current assets within cash used in operating activities. Considering the fixed deposits are classified as a noncurrent asset, please explain why you present the amounts within operating activities and not as an investing activity. Please provide us with the authoritative guidance that supports your presentation.
RESPONSE: We note the Staff’s
comment, and in response thereto, respectfully advise the Staff that we have modified the consolidated statements of cash flows and presented the
fixed deposits in investing activities. Please refer to page F-6 in the Amendment No. 8 to the Registration Statement.
Notes to Consolidated Financial Statements
Note 18 - Subsequent Events, page F-27
2)
You disclose that you have evaluated subsequent events and transactions that occurred after the balance sheet date through the date that the financial statements were available to be issued. Please revise to include such date. Refer to ASC 855-10-50-1.
RESPONSE: We note the Staff’s comment,
and in response thereto, respectfully advise the Staff that we have revised the disclosure on page F-27 in the Amendment No. 8 to the
Registration Statement.
We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact our securities counsel William S. Rosenstadt, Esq., or Mengyi “Jason” Ye, Esq. of Ortoli Rosenstadt LLP at
wsr@orllp.legal or jye@orllp.legal.
Li Bang International Corporation Inc.
/s/ Huang Feng
Name:
Huang Feng
Title:
Chief Executive Officer